Visual images have been associated with food for some time, probably first appearing on the walls of the cave men. Many sketches, drawings, and single "symbolizations," such as that of a grain of wheat, have been associated with food.
One symbol that has been used in the United States in connection with food is a "food pyramid," which was proposed by the United States Department of Agriculture ("USDA") during the 1980's. In the food pyramid, the width of each horizontal slice through the pyramid represents food groups in an overall human diet.
Use of the food pyramid has been limited by the purpose for which it was intended. For example, the food pyramid is not known to have appeared on specific foods or compositions of food (or labels therefor), nor is the symbol particularly suitable for such use, because it pertains to an overall diet rather than to a specific food or a food composition. Selected nutrient information is neither particularized nor quantified. Moreover, the food pyramid does not represent nutrients in quantities normalized to, say, a recommended daily amount.
Instead, the food pyramid was intended for use in generally informing people of the kinds of food that should be included in their overall diets. Therefore, the symbol was not intended to communicate amounts of key nutrients in a specific food composition that is boxed, canned, frozen, or packaged. Nor does the symbol communicate these amounts with respect to a recipe or a restaurant menu item.
For such purposes, instead of using symbols, nutritional quantities have typically been communicated via tables of mathematical quantities or measurements. And until recently, this form of communication has not even been standardized in the United States. Thus, nutrients were displayed in whatever listing the seller felt comfortable displaying, and in whatever format the seller deemed convenient.
This approach could be manipulated to convey misleading information. For example, nutrient values could be normalized to the total weight of the food. Thus, a particular food containing 90% water could be listed as "90% Fat Free," even if the only ingredient other than water is pure fat. Indeed, labeling had so much potential for such manipulation in the recent past that the term "label abuse" had been coined: "Regulators have targeted three major areas of label abuse: deceptive definitions, hazy health claims, and slippery serving sizes." (Time, p. 52, Jul. 15, 1991.)
In a broader view of nutritional labeling, understanding the contents of what one eats is a concern of no small dimension. To this end, there has been a long history in this country of official attempts to develop a national nutrition policy. In principle, it was thought that this policy should make nutritional recommendations (based on the results of dietary research) and that the policy should unify nutritional labeling regulations to make them as honest, fair, and understandable as possible. But implementing a national nutritional policy has not been easy, as summarized in the following excerpt from a book authored by the inventor herein.
Since the 1940's-when standards for enriching grain products and margarine were established, and the school lunch program commenced-the United States has been attempting to develop a national nutritional policy. By the end of the 1960's, the first U.S. nutritional status study was showing results and the White House Conference on Food, Nutrition, and Health met. PA1 Following the release of the somewhat controversial Dietary Goals for the United States by the Senate Select Committee on Nutrition and Human Needs in December 1977, numerous other scientific and federal groups have issued their own nutritional positions. These groups include the National Research Council-National Academy of Sciences (NAS), the Surgeon General, the U.S. Department of Agriculture (USDA), the Food and Drug Administration (FDA), the Department of Health and Human Services (DHHS, formerly the Department of Health, Education and Welfare), and the Federal Trade Commission (FTC). PA1 In February 1980, the USDA and the DHHS developed their guidelines, "Nutrition and Your Health, Dietary Guidelines for Americans." Although all officials involved in preparing the Dietary Guidelines stressed that these guidelines represented a consensus among government scientists on the current state of nutritional knowledge, other agencies--most notably, the Food and Nutrition Board of the National Research Council--voiced their concern that consensus in the interpretation of scientific facts may not be appropriate for the public decision-making process. PA1 (1) the total number of calories PA1 (2) the amount of the following nutrients: total fat, saturated fat, cholesterol, sodium, total carbohydrates, dietary fiber, and total protein contained in each serving size or other unit of measure; and PA1 (3) any vitamin, mineral, or other nutrient required to be placed on the label and labeling of food. PA1 Serving Size 1/2 cup (114 g) PA1 Servings Per Container 4 PA1 Amount per serving PA1 Calories 260; Calories from fat 120 PA1 Conversion Chart
H. C. Kiefer, I. Scarpa, and R. Tatum, Source Book On Nutrition, 3rd. ed., Sec. 1, Marquis Academic Media (Div. Marquis Who's Who Publishers), 1981.
The head of the Department of Health and Human Services called food labeling a "Tower of Babel" because no single agency or law regulated food labeling: the FDA regulated part, the Department of Agriculture regulated part, and the Federal Trade Commission regulated the advertising and labeling of foods and nutrients per se, though individual staten could also make nutrition and labeling laws.
Most of these diverse labeling regulations were finally consolidated and gaps were filled by the Nutrition Labeling and Education Act of 1990. The new law requires, among other things, that food labels disclose the following:
(i) derived from any source, and PA2 (ii) derived from the total fat, in each serving size or other unit of measure of the food, PA2 1 g Fat=9 calories PA2 1 g Carbohydrates=4 calories PA2 1 g protein=4 calories
After the bill was signed into law, the same head of the Department of Health and Human Services was quoted as saying that "The Tower of Babel in food labeling has finally come down . . . " (Time, p. 23, Dec. 14, 1992).
By May 1994, the food industry will have to comply with the requirements of this law. Certain key nutrient information must (by May 1994) appear on all produce bins, meat counters, and the labels of boxed, canned, frozen, etc. food products. And the data must be displayed in such terms as calories, grams, milligrams, and percents--notions that are not immediately easy to visualize. Previously, so far as is known, the conventional approach of providing tables of data has been pursued. A representative post-1992 label is quoted below showing how a label for a food composition can communicate nutrient information so as to comply with the new "Nutritional Labelling and Education Act."
Sample Label
Standardized label information showing number of calories, grams of fat and amounts of other nutrients will be on the labels of all packaged products. Values for a sample diet of both 2,000 and 2,500 calories a day will also be on the label.
Nutritional Information
Nutrition Facts
______________________________________ % Daily Value* ______________________________________ Total Fat 13 g 20% Saturated Fat 5 g 25% Cholesterol 30 mg 10% Sodium 660 mg 28% Total Carbohydrate 31 g 11% Sugars 5 g Dietary Fiber 0 g 0% Protein 5 g ______________________________________ Vitamin A 4%Vitamin C2%Calcium 15% *Percents (%) of a Daily Value are based on a 2,000 calorie diet. Your Daily Values may vary higher or lower depending on your calorie needs: Recommended Daily Amounts 2,000 2,500 Nutrient Calories Calories ______________________________________ Total Fat Less Than 65 g 80 g Sat Fat Less Than 20 g 25 g Cholesterol Less Than 300 mg 300 mg Sodium Less Than 2,400 mg 2,400 mg Total Carbohydrate 300 g 375 g Fiber 25 g 30 g ______________________________________
While extremely valuable in terms of nutritional information, such tables may be difficult for the average consumer to easily understand--quantities expressed as multiple rows of numbers can be daunting, particularly for those who are visually impaired. Thus consumers, who may be unaware of what is good or bad for them, or how much is good or bad for them, may reap limited benefits from the otherwise rather promising new nutritional law. Accordingly, Patrick Boyle, president of the American Meat Institute, supported labeling but called the required label a "morass of numbers . . . neither suitable nor relevant for most Americans." Washington Times, p. 1, Dec. 12, 1992.